Submission on climate-related financial disclosures

The Ministry for the Environment and the Ministry of Business, Innovation and Employment sought feedback on a proposed climate-related financial disclosure regime for organisations.

In our submission, we recognise the importance of climate-related financial disclosure and agree that the recommendations of the Task Force on Climate-related Financial Disclosure (TCFD framework) would be appropriate in New Zealand.

We also:

• note that the ‘comply or explain’ approach to implementing the TCFD framework can support good governance
• raise questions about how the proposed mandatory requirements will fit with the principles-based nature of the TCFD framework, and how it is intended to be implemented, monitored or enforced
• agree that disclosure should apply to listed issuers, banks, general insurers, asset owners and asset managers but we consider that there should be exemptions for some smaller organisations
• agree that mandatory assurance obligations should not be imposed at this stage, and
• encourage government guidance, education and support to help organisations report effectively.